The (re)definition of pasture continues
National Organic Standards Board offers guidance, rule revisions to ensure access to pasture for ruminant livestock

By Jim Riddle

March 25, 2005: During its meeting in Washington, D.C., Feb. 28 through Mar. 3, the National Organic Standards Board adopted two recommendations for changes to the NOP Final Rule and agreed to post a guidance document for another round of public comment concerning access to pasture for organic ruminant livestock, such as dairy cattle. The intent of the Board is to make sure that the requirements for pasture are clear and enforceable.

Prior to the meeting, the National Organic Program (NOP) requested that the NOSB provide guidance concerning the pasture requirements. The NOSB received over 8,000 comments in support of the Livestock Committee’s draft clarifying that pasture is required for organic ruminant animals. In addition, approximately 50 dairy farmers from around the country attended and testified during the meeting.

To review the facts: The NOP Final Rule defines “pasture” as “land used for livestock grazing that is managed to provide feed value and maintain or improve soil, water, and vegetative resources” (7 CFR 205.2).

Pasture for ruminants is required under the Livestock Health Care Practice Standard (7 CFR 205.238) and under Livestock Living Conditions (7 CFR 239). However, the Final Rule does allow for temporary confinement under certain circumstances.

As stated in previous NOSB recommendations, requiring pasture for ruminants ensures that organic production systems provide living conditions in which animals can satisfy their natural behavior patterns, emphasize preventative measures for animal health care, and answer consumer expectations of humane animal management. Ideally, organic pasture management should reflect a synthesis of crop and livestock production principles that work from the soil up to promote an interdependent community of plants and ruminants.

Recommended rule changes

In order to clarify that pasture is required during the growing season, throughout the productive life of the animal, the NOSB recommended the following rule changes:

  1. Recommended rule change for §205.239(a)(2)

    The language in §205.239(a)(2) would be amended to read:
    §205.239(a)(2) Access to pasture for ruminants Ruminant animals grazing pasture during the growing season.

    This includes all stages of life except:
    a) birthing; b) dairy animals up to 6 months of age; and c) beef animals during the final finishing stage, not to exceed 120 days. Note: Lactation of dairy animals is not a stage of life under which animals may be denied pasture for grazing.

  2. Recommended rule change for 205.239(a)(1) and 205.239(b)(2)

    Language within the Final Rule is ambiguous with respect to how specific provisions apply to livestock at different stages of life. Sections 205.239(a)(1) and 205.239(b)(2) use the term “stage of production” with regard to access to the outdoors and temporary confinement. Section 205.237 (a)(2), however, uses the term “stage of life” to describe the allowance for specific levels of feed supplements or additives.

    Development of enforceable standards for “stage of production” is problematic, particularly for dairy animals. While “life” encompasses the total span of an animal’s life, “production” could be understood to refer only to that portion of life during which the animal produces milk.

    The NOSB recommends a rule change to make the language in §205.239(a)(1) and §205.239(b)(2) consistent with the language in §205.237(a)(2). The language in §205.239(a)(1) would be amended to read, “Access to outdoors, shade, shelter, exercise areas, fresh air, and direct sunlight suitable to the species, its stage of production life, the climate, and the environment.

    The language in §205.239(b)(2) would be amended to read “animal’s stage of production life.”

NOSB guidance on access to pasture

What follows is the NOSB's draft guidance language regarding access to pasture for ruminant livestock. The NOSB welcomes public comment on the draft until May 20, 2005.

Guidance for interpretation of §205.239(a)(2)

Action Alert

The NOSB is seeking public comment on its “Livestock Committee Recommendation for Guidance Pasture Requirements” until May 20, 2005. The draft guidance language is reproduced here, or it can be downloaded from

Comments can be submitted by:

  • Mail: The National Organic Standards Board; c/o Arthur Neal; Room 4008 - South Building; 1400 and Independence Avenue, SW; Washington, D.C. 20250-0001
  • E-mail:
  • Fax: (202) 205-7808

Comments are welcome on organic system plan requirements; temporary confinement; and what constitutes “appropriate pasture conditions.” In particular, the NOSB seeks input on specific "dry matter intake from pasture" language; reference to regional NRCS prescribed grazing standards; and whether or not any of the text below should be recommended to the NOP for rule changes.

Please clearly indicate if you are for or against the Board recommendation, or some part of it, and why. Include specific recommended wording changes as appropriate, and feel free to include copies of articles or other references that support your comments. Only relevant material should be submitted.

A. Organic System Plan

Ruminant livestock shall graze pasture during the months of the year when pasture can provide edible forage. The Organic System Plan shall have

e goal of providing grazed feed greater than 30% dry matter intake on a daily basis during the growing season but not less than 120 days. The Organic System Plan shall include a timeline showing how the producer will satisfy the goal to maximize the pasture component of total feed used in the farm system. For livestock operations with ruminant animals, the operation’s Organic System Plan shall describe: 1) the amount of pasture provided per animal; 2) the average amount of time that animals are grazed on a daily basis; 3) the portion of the total feed requirement that will be provided from pasture; 4) circumstances under which animals will be temporarily confined; and 5) the records that are maintained to demonstrate compliance with pasture requirements.

B. Temporary Confinement

Temporary confinement means the period of time when ruminant livestock are denied pasture. The length of temporary confinement will vary according to the conditions on which it is based (such as the duration of inclement weather) and instances of temporary confinement shall be the minimum time necessary. In no case shall temporary confinement be allowed as a continuous production system. All instances of temporary confinement shall be documented in the Organic System Plan and in records maintained by the operation.

Temporary confinement is allowed only in the following situations:

  1. During periods of inclement weather such as severe weather occurring over a period of a few days during the grazing season;
  2. Conditions under which the health, safety, or well being of an individual animal could be jeopardized, including to restore the health of an individual animal or to prevent the spread of disease from an infected animal to other animals;
  3. To protect soil or water quality

C. Appropriate Pasture Conditions

Appropriate pasture conditions shall be determined in accordance with the regional Natural Resources Conservation Service Conservation Practice Standards for Prescribed Grazing (Code 528) for the number of animals in the Organic Systems Plan.

Jim Riddle is chair of the National Organic Standards Board and a regular contributor to

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